SUPERIOR COURT OF THE STATE OF ARIZONA
COUNTY OF [COUNTY]
[PLAINTIFF NAME],
Plaintiff,
v. Case No.: [CASE NUMBER]
[DEFENDANT NAME],
Defendant.
PLAINTIFF’S FIRST SET OF NON-UNIFORM INTERROGATORIES TO DEFENDANT
[// GUIDANCE: Tailor the caption to match the exact style used by the assigned division of the Arizona Superior Court (e.g., add “HON. [JUDGE]” line if customary in that county).]
TABLE OF CONTENTS
- Preliminary Statement
- Applicable Rules, Discovery Limits, and Deadlines
- Definitions
- General Instructions
- Specific Interrogatories (Nos. 1-[NUMBER])
- Verification
- Certificate of Service
1. PRELIMINARY STATEMENT
Plaintiff propounds the following non-uniform interrogatories (“Interrogatories”) to Defendant pursuant to Rules 26–37 of the Arizona Rules of Civil Procedure (“ARCP”), specifically ARCP Rule 33 governing interrogatories. These Interrogatories are continuing in nature; Defendant must seasonably supplement its answers as required by ARCP 26(e).
2. APPLICABLE RULES, DISCOVERY LIMITS, AND DEADLINES
2.1 Numerical Limit. Absent stipulation or court order, the total number of non-uniform interrogatories a party may serve in an Arizona civil action is limited by ARCP 33. The limit presently in effect is [40] interrogatories, including discrete subparts.
[// GUIDANCE: Confirm the current limit—Rule 33 has been amended multiple times.]
2.2 Response Time. Defendant must serve written, verified answers and any objections within 30 days after service of these Interrogatories, except that if they are served with the summons and complaint, Defendant has 40 days under ARCP 33 to respond.
2.3 Form of Answer. Each answer must be preceded by the text of the corresponding Interrogatory, be in writing, and be signed and verified by the party—not solely by counsel—as mandated by ARCP 33(b)(2).
2.4 Privilege & Work-Product Assertions. When withholding information on the basis of attorney-client privilege, work-product doctrine, or any other protection, Defendant must:
a. State the specific privilege claimed; and
b. Provide a privilege log that complies with ARCP 26(b)(6), identifying the nature and subject matter of the information withheld sufficient to enable Plaintiff and the Court to assess the propriety of the claim.
3. DEFINITIONS
For purposes of these Interrogatories, the following defined terms apply. Undefined capitalized terms carry their ordinary meaning.
“Communication” means any oral, written, electronic, or other transfer of information, including without limitation emails, text messages, social-media posts or messages, meetings, and telephone calls.
“Concerning,” “Relating to,” or “Regarding” means directly or indirectly mentioning, describing, reflecting, evidencing, constituting, or in any way pertaining to the subject matter identified.
“Document” is used in the broadest sense permissible under ARCP 34 and includes electronically stored information (“ESI”).
“Identify” or “Identity” when used with respect to:
a. A natural person—provide the person’s full name, present or last-known address, telephone number, and employer and position at the time relevant to the Interrogatory;
b. A business entity—state its full legal name, address of headquarters, and the identity of its principal officers;
c. A document—state its title, date, author(s), recipient(s), type (e.g., email, memo), and present custodian.
“Incident” means the occurrence described in the Complaint dated [COMPLAINT DATE].
4. GENERAL INSTRUCTIONS
4.1 Rules of Construction. Singular shall include plural and vice-versa; masculine, feminine, and neuter include each other; the term “and/or” shall be construed broadly to require inclusive answers.
4.2 Supplementation. These Interrogatories are continuing; if Defendant obtains additional responsive information, Defendant must supplement its answers promptly as required by ARCP 26(e).
4.3 Objections. State each objection with specificity. Do not recite boilerplate or “general objections.” If an Interrogatory is partially objectionable, answer the unobjectionable portion.
4.4 Computation of Time. Compute all periods of time under ARCP 6(a).
4.5 Meet and Confer. If a dispute arises concerning these Interrogatories, counsel must engage in a good-faith personal consultation pursuant to ARCP 26(g) before filing any discovery motion.
5. SPECIFIC INTERROGATORIES
[// GUIDANCE: Insert, revise, or delete Interrogatories to fit the case. Number consecutively; ensure the total—including subparts—does not exceed the Rule 33 limit.]
Interrogatory No. 1
Identify every person whom you believe has knowledge of any fact alleged in the Complaint or your Answer, and for each such person describe the subject matter of his or her knowledge.
Interrogatory No. 2
State the factual basis for each affirmative defense asserted in your Answer, identifying all documents and witnesses that support each defense.
Interrogatory No. 3
Describe in detail the sequence of events constituting the Incident, specifying dates, times, participants, and the location of each event.
Interrogatory No. 4
Itemize and describe any damages you contend were caused by Plaintiff, including the method of calculation and identification of all supporting documents.
Interrogatory No. 5
Identify all insurance agreements under which an insurance business may be liable to satisfy all or part of a potential judgment in this action, stating for each:
a. Name of insurer;
b. Policy number;
c. Coverage limits; and
d. Applicable deductibles or self-insured retentions.
[Continue through Interrogatory No. [NUMBER]…]
6. VERIFICATION
I, [DEFENDANT REPRESENTATIVE NAME], hereby declare under penalty of perjury under the laws of the State of Arizona that I am the [TITLE/POSITION] for Defendant [DEFENDANT NAME]; that I have read the foregoing Answers to Interrogatories and know the contents thereof; and that the answers and objections are true and correct to the best of my knowledge, information, and belief.
Date: __ ____
[NAME]
[TITLE/POSITION]
For [DEFENDANT NAME]
[// GUIDANCE: Arizona requires the party—not just counsel—to verify. Use an unsworn declaration under A.R.S. §12-2291 or a notarized jurat. Adjust if the court prefers notarization.]
7. CERTIFICATE OF SERVICE
I certify that on [SERVICE DATE], I served the foregoing Plaintiff’s First Set of Non-Uniform Interrogatories to Defendant on all counsel of record via [e-mail/E-Service/First-Class Mail] in accordance with ARCP 5(b).
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[EMAIL]
Attorney for Plaintiff
[// GUIDANCE:
1. Confirm county-specific e-service preferences (some counties require AZTurboCourt).
2. If more than one defendant exists, serve each separately or revise caption accordingly.
3. Track the date of service precisely; the response deadline runs from that date under ARCP 6 & 33.]